NG-06-0622, Request to Allow Use of the Provisions of IWA-4132 for the Remainder of the Third 10-Year Inservice Inspection Interval and the Fourth Ten-Year Inservice Inspection Interval
| ML062780201 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/29/2006 |
| From: | Vanmiddlesworth G Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NG-06-0622 | |
| Download: ML062780201 (5) | |
Text
FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 FPLEnergy.
Duane Arnold Energy Center September 29, 2006 NG-06-0622 10 CFR 50.55a(a)(3)(i)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Request To Allow Use Of The Provisions Of IWA-4132 For The Remainder Of The Third 10-Year Inservice Inspection Interval And The Fourth Ten-Year Inservice Inspection Interval Pursuant to 10 CFR 50.55a(a)(3)(i), FPL Energy Duane Arnold, LLC, (hereafter, FPL Energy Duane Arnold) hereby requests NRC approval of the enclosed request for the remainder of the third ten-year Inservice Inspection Interval and the fourth ten-year Inservice Inspection Interval. DAEC is currently in its third ten-year interval, scheduled to end on October 31, 2006. This request is for the application of the provisions of IWA-4132 to the stock rotation of Recirculation Pump Seal Flange Assemblies.
FPL Energy Duane Arnold, requests approval of this request by the end of September 2007.
If you have any questions or require additional information, please contact Steve a
Va Middlesworth Site e President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC Enclosure cc:
Administrator, Region III, USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC Awqz
ENCLOSURE Request To Allow Use Of The Provisions Of IWA-4132 For The Remainder Of The Third 10-Year Inservice Inspection Interval And The Fourth Ten-Year Inservice Inspection Interval
- 1. ASME Code Component(s) Affected Code Class:
I
References:
IWA-4000 1 OCFR50.55a(b)(2)(xxvi)
Examination Category:
N/A Item Number:
N/A
==
Description:==
Relief to use the provisions of IWA-4132 for the stock rotation of Recirculation Pump Seal Flange Assemblies Component Number N/A
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Section X1, 1992 Edition with the 1992 Addenda for the remainder of the third ten-year interval, and the 2001 Edition with the 2003 Addenda for the fourth ten-year interval.
3. Applicable Code Requirement
The DAEC third ten-year interval uses the ASME Section Xl, 1992 Edition with the 1992 Addenda for repair/replacement activities. IWA-4710 (c) requires "mechanical joints made in the installation of pressure retaining replacements shall be pressure tested in accordance with IWA-521 1(a). "
The DAEC fourth ten-year interval will use the ASME Section X1, 2001 Edition with the 2003 Addenda. 10CFR50.55a(b)(2)(xxvi) states, "Pressure Testing Class 1, 2, and 3 Mechanical Joints. The repair and replacement activity provisions in IWA-4540(c) of the 1998 Edition of Section XI for pressure testing Class 1, 2, and 3 mechanical joints must be applied when using the 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section." IWA-4540(c) of the 1998 Edition of Section XI requires mechanical joints made in installation of pressure retaining items shall be pressure tested in accordance with IWA-521 1(a).
Thus, both the third and fourth ten-year intervals invoke IWA-5211 (a) for the pressure testing of mechanical joints on pressure retaining items.
Page 1 of 4
4. Reason for Request
IWA-4132 of the 2001 Edition with the 2003 Addenda of ASME Section XI provides specific requirements for items rotated from stock for the purposes of testing. The items specifically mentioned are snubbers and relief valves. FPL Energy Duane Arnold believes the criteria established in IWA-4132 for snubbers and pressure relief valves for testing can also be applied to the stock rotation of Recirculation Pump Seal Flange Assemblies for preventative maintenance, given that all the cited stock rotations involve mechanical joints on pressure retaining items and that none of these stock rotations involve a repair/replacement activity.
Non-mandatory Appendix J of the ASME Section XI code provides guidance to help the users of the code determine the applicability of IWA-4000. This appendix establishes that repair/replacement activities are separate from maintenance activities. The examples that are given for repair/replacement activities are:
- 1.
removing weld or material defects;
- 2.
reducing the size of defects to a size acceptable to the applicable flaw evaluation criteria;
- 3.
performing welding or brazing;
- 4.
adding items;
- 5.
system changes, such as rerouting of piping;
- 6.
modifying items;
- 7.
rerating.
The stock rotation of seal flange assemblies does not fall under these examples.
The disassembly and re-assembly of the mechanical connection for the stock rotation of spare Recirculation Pump Seal Flange assemblies is considered a maintenance activity and thus, the use of IWA-4132 for these activities provides an acceptable level of quality and safety, per 1 OCFR50.55a.
The criteria established in 10CFR50.55a(b)(2)(xxvi) would not apply unless there was a repair/replacement activity performed on the spare Recirculation Pump Seal Flange Assembly prior to installation, then a pressure test in accordance with the IWA-4540(c) of the 1998 Edition would be performed.
5. Proposed Alternative and Basis for Use
The Recirculation Pump Seal Flange Assembly consists of the seal cartridge and the seal flange. The seal flange is a pressure boundary component that supports the seal cartridge. The entire assembly (seal flange and seal cartridge) is bolted to the pump casing. During maintenance on the seal cartridge the complete assembly (seal cartridge and flange) is rotated as a single unit.
Page 2 of 4
The basis for IWA-4132 is the normal activity of testing components involves removal from their installed location by mechanical means (i.e., disassembly and re-assembly of mechanical joints.) IWA-4132 recognizes that rather than re-install the same component after being tested, a similar component from stock can be rotated into service in its place. FPL Energy Duane Arnold believes the criteria established in IWA-4132 for stock rotation of snubbers and pressure relief valves for testing can also be applied to the stock rotation of Recirculation Pump Seal Flange Assemblies for preventative maintenance.
Per IWA-4132:
(a) Items being removed and installed shall be of the same design and construction.
(b) Items being removed shall have no evidence of failure at the time of removal.
(c) Items being rotated shall be removed and installed only by mechanical means.
(d) Items being installed shall previously have been in service.
(e) Preservice inspections shall be performed as required by IWA-4500.
(f) The Owner shall track the items to ensure traceability of inservice inspection and testing records.
(g) Use of an Inspector and an NIS-2 form are not required.
(h) Testing of removed snubbers, including required sample expansions, shall be performed in accordance with Subsection IWF.
The above criteria will be adopted by FPL Energy Duane Arnold for stock rotation of Recirculation Pump Seal Flange Assemblies, as described below:
- 1.
The seal flange assembly being installed will be a like-for-like replacement (same design) and built to the same construction code.
- 2.
The seal flange assembly will have no evidence of failure (failure being defined as the pressure boundary failure).
- 3.
The seal flange assembly will be removed and installed by mechanical means.
- 4.
The seal flange assembly will have been previously installed.
- 5.
Preservice and inservice inspections will be completed (i.e. Visual VT-1 of the bolting).
- 6.
As the seal flange assembly is installed, the work will be controlled under the work order process. Unique identification for each item will be tracked and controlled.
- 7.
An Inspector and NIS-2 form will not be used unless the item being installed has been repaired/replaced* in accordance with IWA-4000.
Page 3 of 4
- 8.
Testing of the seal flange assembly will be completed as needed to determine acceptability.
- If there is a repair/replacement activity performed on the item to be installed, IWA-4000 will be followed, including the use of an Inspector, NIS-2 form, and pressure testing.
FPL Energy Duane Arnold has one spare Recirculation Pump Seal Flange Assembly for the DAEC, which is used as stock rotation for preventive maintenance. The Recirculation Pump Seal Flange Assembly is rotated from stock when the mechanical seal starts to show signs of wear prior to its failure.
This spare Recirculation Pump Seal Flange Assembly has been previously installed and subsequently refurbished. FPL Energy Duane Arnold considers this stock rotation to be a maintenance function (disassembly and re-assembly of mechanical joints) and not a repair/replacement activity, per IWA-4000.
Since IWA-4132 does not specifically include the stock rotation of Recirculation Pump Seal Flange Assemblies, FPL Energy Duane Arnold requests the use of the criteria stated above for the stock rotation of Recirculation Pump Seal Flange Assemblies as an alternative to the requirements of IWA-4000 that includes performing pressure testing as required by IWA-4710(c) of the 1992 Edition with the 1992 Addenda for the third ten-year interval, and IWA-4540(c) of the 1998 Edition for the fourth ten-year interval.
It is important to note that IWA-4132 of the 2004 Addenda of the ASME Section XI code includes preventative maintenance in the rotation of stock items.
Because the basic activity of disassembly and re-assembly of the mechanical joint is the same between the requested activity and that currently permitted, the proposed alternative would provide an acceptable level of quality and safety, and would not adversely impact the health and safety of the public.
6. Duration of Proposed Alternative
This alternative will be used for the remainder of the DAEC third ten-year interval and the fourth ten-year inspection interval.
Page 4 of 4